The American Counseling Association (ACA), in addition to other mental health organizations, submitted comments to the Centers for Medicare and Medicaid Services (CMS) on how the 2023 Medicare Physician Fee Schedule Proposed Rule’s “general supervision” requirement affects the counseling profession. As CMS indicates, “general supervision” is a more flexible type of supervision that would not require the Medicare-eligible provider to be present in the clinic when an LPC or LMFT treats a Medicare beneficiary, although the Medicare-eligible provider must still submit the reimbursement claim. Although this rule’s “general supervision” clause will positively impact the counseling profession, ACA shared in its comments that “without Congressional action, CMS’s ability to expand Medicare beneficiaries’ access to LPCs and LMFTs is limited,” but ACA will “support all steps CMS can take to increase beneficiary access to these practitioners within its regulatory authority.”
The ACA provided the following recommendations to CMS:
- Recommendation 1 - Include Associate Counselors completing their supervised clinical training requirements to be “auxiliary personnel”
- Recommendation 2 - Clarify Supplemental Payer Coverage Requirements
Read the full comments submitted by ACA here.